The Medicare Payment Advisory Commission (“MedPAC”) is an independent US federal body that advises the United States Congress on issues affecting the administration of the Medicare program. In early October, MedPAC met and two topics were discussed impacting nurse practitioners (“NPs”) and physician assistants (“PAs”). Specifically, MedPAC is recommending some approaches that start to blend the world of NPs, PAs, and physicians.
Incident To Billing
MedPAC’s first issue discussed related to incident to billing with NPs and PAs. Incident to billing can be complex but the bottom line is that incident to billing allows a visit by a PA or NP to be billed at 100% of the physician fee schedule. If an NP or PA billed the same visit directly, the reimbursement would be limited to 85%. The interesting part about incident to billing is that it was implemented prior to NPs or PAs truly operating as a large profession. To quote MedPAC board member, “incident-to billing is a relic of the Medicare of the late 1960s where the program was completely passive.”
The policy recommendation to MedPAC was to eliminate incident to billing which accounts for approximately 5% of Medicare evaluation and management office visits. The board was supportive of this recommendation for many reasons including that the role of NPs and PAs is that of a provider in most cases. Overall though, this recommendation might have a significant impact on practices relying in this type of revenue.
Specialty Designations
MedPAC also discussed enrolling NPs and PAs with specialty designations, similar to that of physicians. Currently, Medicare clasifies all NPs as one specialty and all PAs as one specialty. The recommendation to MedPAC was to explore identifying the specialty designations. This not only treats NPs and PAs from a categorical perspective like physicians, but also allows Medicare to understand how different specialties of NPs and PAs service patients.
One additional issue raised by a board member was allowing NPs and PAs to attend medical school in a more streamlined manner. For example, right now an NP or PA would have to start completely over to pursue medical school. Nevertheless, while these are only recommendations, interested parties should not take this conversation lightly.